MEMS processes are often characterised by the construction of conductive layers in multilayered structures such as actuator devices or the like. Often, it is important for these conductive layers to be in thermal contact with an adjacent material where the conductive layer is utilised as a heater element to instigate the actuation of an active device of the micro-electro mechanical system. The conductive layer material is typically a different material than the material utilised in the adjacent, thermally active layer, creating problems associated with the formation of such active, multilayered structures such as de-lamination and in-efficient thermal connection which can cause problems in the device performance and ultimately devices may stop functioning.